Occupational Health · Mandatory · Construction

Audiometric Health Surveillance Record

The audiometric health surveillance record for workers exposed above the upper EAV (85 dB(A)). Documents baseline and periodic pure tone audiograms, significant threshold shift detection at 4 kHz, and fitness for work outcomes. NIHL is reportable under RIDDOR. Records must be retained for 40 years.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. Control of Noise at Work Regulations 2005 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basis	Control of Noise at Work Regulations 2005 (CNWR 2005) Reg 9
Baseline audiogram	Must be completed before or within the first few weeks of noise-exposed work — establishes the reference point for all future comparisons
Periodic testing	Annually for the first 2 years of noise-exposed work, then every 3 years thereafter
Record retention	40 years from date of last entry
RIDDOR	NIHL (noise-induced hearing loss) is reportable under RIDDOR 2013 as a Schedule 1 occupational disease

1. Audiometric Surveillance — Catching Hearing Loss Before It Becomes Permanent

Audiometric health surveillance is the systematic monitoring of workers' hearing over time to detect early signs of noise-induced hearing loss before the damage becomes disabling. The system relies on establishing a baseline audiogram at the start of noise-exposed work and then comparing periodic audiograms against that baseline to identify any significant threshold shift — a deterioration in hearing at specific frequencies that indicates noise damage is occurring.

The characteristic audiometric signature of NIHL is a notch at 4 kHz (4000 Hz), where hearing sensitivity is significantly worse than at adjacent frequencies. This pattern distinguishes noise damage from age-related hearing loss (presbycusis), which produces a more gradual decline across higher frequencies. Early detection of a 4 kHz notch or significant threshold shift triggers a review of the worker's noise exposure and controls, referral to occupational health, and consideration of whether the case is reportable under RIDDOR.

Audiometric testing must be conducted by a trained audiometric technician using calibrated equipment in a suitable environment with sufficiently low background noise. Workers should avoid noise exposure for at least 16 hours before the test (a “noise-free period”) to ensure the results reflect permanent threshold shift rather than temporary threshold shift caused by recent noise exposure.

Baseline timing is critical

Conduct baseline audiometry before or within the first few weeks of noise-exposed work — not months later. A delayed baseline may already include early noise damage, making it impossible to detect subsequent deterioration accurately.

2. Key Components

The following table sets out the key components that an audiometric health surveillance record must address. Each element supports the 40-year record obligation and provides the clinical and occupational context for fitness for work decisions.

Component	Detail
Worker details	Full name, date of birth, NI number, employer, trade/role — sufficient to identify the individual across 40 years of records
Test date	Date of each audiometric test — baseline and all periodic tests must be dated and sequenced chronologically
Test type	Whether the test is a baseline audiogram, periodic audiogram (annual or 3-yearly), or follow-up audiogram triggered by a previous abnormal result
OH provider	Name of the occupational health provider, audiometric technician, and the testing facility — must be competent and using calibrated equipment
Noise exposure context	Summary of the worker's noise exposure since the last test — tasks, noise levels, daily L_EP,d, duration of exposure, and hearing protection used
Audiogram results	Hearing thresholds at standard test frequencies (0.5, 1, 2, 3, 4, 6, 8 kHz) for both ears — recorded in dB HL (hearing level)
Significant threshold shift?	Whether the periodic audiogram shows a significant deterioration compared to the baseline — typically defined as a shift of ≥10 dB at 2, 3, or 4 kHz averaged across both ears, or a 4 kHz notch
Outcome	Clinical outcome — no significant change, threshold shift requiring review, referral for specialist assessment, categorisation (1–5 under HSE guidance), or fitness restriction
RIDDOR required?	Whether the case is reportable under RIDDOR 2013 — NIHL confirmed by a doctor where the worker has been regularly exposed to noise at or above the upper EAV is a reportable occupational disease
Next surveillance due	Date of the next scheduled audiometric test — annually for first 2 years, then every 3 years, or more frequently if threshold shift is detected
Record retention	40 years from date of last entry — audiograms and associated records must be stored securely for the full retention period

3. Common Mistakes

Taking baseline audiograms months into noise-exposed work

The baseline audiogram must be completed before or within the first few weeks of noise-exposed work. A baseline taken months after the worker has started noise-exposed tasks may already reflect early noise damage, which then becomes the reference point for all future comparisons. This means that subsequent deterioration will be measured against an already-damaged baseline, making it impossible to detect the full extent of noise-induced hearing loss. The baseline should ideally be taken after a 16-hour noise-free period.

Not acting on significant threshold shift

When a periodic audiogram reveals a significant threshold shift compared to the baseline, the employer must take action: review the worker's noise exposure and the effectiveness of existing controls, refer the worker to occupational health for further assessment, consider whether the case is reportable under RIDDOR, and review whether other workers performing similar tasks are adequately protected. Simply recording the result without taking action defeats the purpose of the surveillance programme.

4. Frequently Asked Questions

Is NIHL reportable under RIDDOR?▾

Yes. Noise-induced hearing loss is a reportable occupational disease under RIDDOR 2013, Schedule 1. Where a worker who has been regularly exposed to noise at or above the upper exposure action value of 85 dB(A) is diagnosed by a doctor as having noise-induced hearing loss, the employer must report it to the HSE within 15 days of the date of diagnosis. The report is made using the online RIDDOR reporting system. Failure to report is a criminal offence.

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